Dashrath Rupsingh Rathod v. State of Maharashtra
Supreme Court of India(2014) 9 SCC 129The Court held that jurisdiction under S.138 lies only with the court within whose jurisdiction the bank on which the cheque is drawn (the drawer's/drawee bank) is situated. The five-point test in K. Bhaskaran was restricted to a single-point test. The judgment created unprecedented chaos — all pending Section 138 complaints filed at the payee's bank location became jurisdictionally questionable. Parliament reacted swiftly: the Negotiable Instruments (Amendment) Act, 2015 overturned this judgment prospectively, fixing jurisdiction at the payee's collecting bank.